2 Your Personal Information
The Spa at Salt only collects personal information (being information that identifies or could reasonably identify an individual) where The Spa at Salt considers it to be reasonably necessary for The Spa at Salt’s services, functions and activities. The Spa at Salt collects personal information to deliver our products and service to members and customers including in circumstances when:
The types of information The Spa at Salt collects includes:
3 Your Sensitive Information
Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record. It is The Spa at Salt’s policy to only collect your sensitive information where it is reasonably necessary for The Spa at Salt functions or activities and either you have consented or The Spa at Salt are required or authorised under law to do so.
4 How The Spa at Salt collects your personal information
The Spa at Salt will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.
The Spa at Salt will collect directly personal information:
The Spa at Salt may collect information from third parties including:
5 Using your personal information
The main purposes for which The Spa at Salt collects, holds, uses and discloses personal information are to provide services and benefits to members and casual visitors, and to grow The Spa at Salt’s membership.
The Spa at Salt collects information to service its members and casual visitors. The Spa at Salt can use your information to:
The Spa at Salt’s website requires subscriptions or registrations to use certain services, functions or content. You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. The Spa at Salt will collect data relating to any transactions you carry out through The Spa at Salt’s website and the fulfilment of your order. The Spa at Salt may also use your data to monitor for any unauthorised use of The Spa at Salt’s website, content or subscriptions to The Spa at Salt’s services.
6 Purpose of collection
If The Spa at Salt collects personal information for a purpose (the primary purpose), The Spa at Salt will not use or disclose the information for any other purpose (the secondary purpose) unless:
If The Spa at Salt uses or discloses your information because The Spa at Salt reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, The Spa at Salt will make a written note of the use or disclosure.
7 Do you have to provide personal information?
You can refuse to provide personal information. However, a refusal may mean that the service you requested is not provided or membership will be refused or forfeited.
8 Sharing your personal information
The Spa at Salt may use and disclose personal information for related purposes to third parties. Types of organisations to whom The Spa at Salt may disclose your personal information includes:
The Spa at Salt does not rent, sell or exchange your personal information to third parties without your prior approval.
9 Government Identifiers
The Spa at Salt does not, adopt, use or disclose government related identifiers (such as a Medicare number or license number) as The Spa at Salt’s own identifier for you unless:
To improve The Spa at Salt’s services, The Spa at Salt sometimes collects de-identified information from web users. The information collected does not identify an individual but does help The Spa at Salt to analyse and improve its web services. When you visit The Spa at Salt’s website, a record of your visit is logged and the following data is supplied by your browser:
The Spa at Salt uses this information to customise the website for visitors and to collect data for analysis, quality control, administration and improving the website. It is not used for any other purpose. Aggregated data may be shared with third parties.
You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.
11 Links to other websites
Links to third party websites that The Spa at Salt does not operate or control are provided for your convenience. The Spa at Salt is not responsible for the privacy or security practices of those websites. Third party websites should have their own privacy and security policies which The Spa at Salt encourages you to read before supplying any personal information to them.
12 Direct Marketing
If The Spa at Salt holds your information, The Spa at Salt may use or disclose that information (other than sensitive information) for direct marketing if:
The Spa at Salt can use or disclose your sensitive information for the purpose of direct marketing, if you have consented to the use or disclosure of that information for direct marketing. The Spa at Salt may also use or disclose your personal information for direct marketing if:
If The Spa at Salt has collected the personal information that The Spa at Salt used to send you direct marketing material from a third party, you can ask The Spa at Salt to notify you of its source of information. It is The Spa at Salt’s policy is to do so unless it is unreasonable or impracticable.
13 How to opt out of direct marketing
If The Spa at Salt uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from The Spa at Salt.
If the Spa at Salt uses or discloses your personal information for the purpose of facilitating direct marketing by other organisations, you may request that The Spa at Salt does not use or disclose your information for this purpose.
The Spa at Salt will give effect to your request not to receive direct marketing from The Spa at Salt or an entity facilitated by The Spa at Salt within a reasonable time after the request is made.
14 Protecting your personal information
The Spa at Salt stores information in different ways, including paper and electronic form. The Spa at Salt takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure including:
The Spa at Salt cannot guarantee that personal information will be protected against unauthorized access or misuse and The Spa at Salt does not accept any liability for the improper actions of unauthorised third parties.
The Spa at Salt will retain your personal information for as long as necessary to fulfil The Spa at Salt’s obligations to you, to protect its legal interests, to comply with laws or as otherwise stated to you when The Spa at Salt collects your personal information.
Once the Spa at Salt is no longer required to retain your personal information, The Spa at Salt will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified.
15 Disclosing your personal information overseas
The Spa at Salt may disclose your personal information to other third party service providers operating outside Australia who work with The Spa at Salt or one of The Spa at Salt’s suppliers, agents, or partners. The Spa at Salt may also store your personal information on servers based overseas or in the “cloud” or other types of networked or electronic storage.
Before disclosing your personal information to an overseas third party, The Spa at Salt will first take reasonable steps to ensure that the overseas recipient:
Personal information may be disclosed by The Spa at Salt to other The Spa at Salt entities and third parties in jurisdictions including: Australia, New Zealand, United States of America and the Netherlands. The European Commission has recognized each of these countries as providing adequate protection of personal information.
You acknowledge and understand that by providing such consent:
If you withdraw consent, The Spa at Salt will not rely on this consent when dealing with your personal information going forward.
You have the option of not identifying yourself or using a pseudonym when dealing with The Spa at Salt provided that is it lawful and practicable.
The Spa at Salt will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if:
It is The Spa at Salt’s policy to enable you to access The Spa at Salt’s website and make general phone queries without having to identify yourself and to enable you to respond to The Spa at Salt’s surveys anonymously.
In some cases, however, if you don’t provide The Spa at Salt with your personal information when requested, The Spa at Salt may not be able to respond to your request or provide you with our service. For example, you must identify yourself to become a The Spa at Salt member.
17 Accessing to your personal information
You have the right, upon request, to access any of The Spa at Salt’s records containing your personal information. To request access to your personal information please contact the Privacy Officer, set out at the end of this Policy.
The Spa at Salt will respond to your request to access your personal information within a reasonable period of time.
On the basis that it is reasonable and practicable to do so, The Spa at Salt will give you access to the information requested.
If the Spa at Salt refuses your request to access personal information, The Spa at Salt will provide a written notice setting out the reasons for the refusal & how you can complain about the refusal.
Reasons for a refusal may include if it:
When you make a request to access personal information, The Spa at Salt will require you to provide some form of identification (such as a driver’s licence or passport) so The Spa at Salt can verify that you are the person to whom the information relates.
18 Help The Spa at Salt keep your personal information accurate
The Spa at Salt will take reasonable steps to ensure The Spa at Salt’s records of personal information are accurate, up to date and complete.
However, the accuracy of information depends to a large extent on the information you provide. If you do not give The Spa at Salt all the personal information The Spa at Salt may require, or the personal information provided is inaccurate or incomplete, then the products, services and information The Spa at Salt provide may be affected.
If you think there is something wrong with the information The Spa at Salt holds about you please contact the Privacy Officer to:
The Spa at Salt will respond to your request to correct your personal information and in a reasonable period of time. If The Spa at Salt refuses your request, The Spa at Salt will provide you with a written notice setting out the reasons for the refusal and mechanisms available to complain about the refusal.
If The Spa at Salt refuses to correct your personal information, you may request that The Spa at Salt associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. The Spa at Salt will take reasonable steps to make the statement visible to users of your personal information.
If The Spa at Salt does correct your personal information and The Spa at Salt has previously disclosed your personal information to a third party, upon your request, The Spa at Salt will notify that third party of the correction unless it is impracticable or unlawful to do so.
19 Resolving your privacy issues
If you have any issues you wish to discuss with The Spa at Salt or if you’re concerned about how The Spa at Salt has collected or managed your personal information please contact the Privacy Officer.
For information about privacy or if your concerns are not resolved, contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
21 The Spa at Salt Privacy Officer
The Spa at Salt’s privacy officer can be contacted at: